Due Diligence in Turkey: Legal, Tax, and Commercial Checklist for M&A

Buying a company in Turkey can be a great opportunity—but only if you understand what you’re actually buying. Many M&A problems are not “business problems,” they’re hidden liability problems: tax and SGK exposure, undisclosed litigation, invalid contracts, missing permits, informal related-party dealings, or assets that don’t legally belong to the company. The tool that prevents these surprises is due diligence.

This SEO-focused guide explains due diligence in Turkey for M&A: what it covers, what buyers should prioritize, a practical checklist (legal, tax, financial, and commercial), red flags unique to Turkey, and how findings are converted into SPA protections like warranties, indemnities, escrow/holdback, and price adjustments.


1) What Is Due Diligence in Turkey?

Due diligence is a structured investigation of the target company before signing and/or closing. The goal is to:

  • confirm ownership and corporate authority,
  • identify liabilities and compliance gaps,
  • validate financial quality and cashflows,
  • map key contracts and operational dependencies,
  • price and allocate risks in the SPA.

Practical point: In Turkey, due diligence is often the only time a buyer can force transparency. After closing, your leverage drops.


2) The Core Types of Due Diligence

Most Turkish M&A deals use a combination of:

  • Legal due diligence (corporate, contracts, disputes, permits, assets)
  • Tax due diligence (VAT, withholding, corporate income tax, audits, transfer pricing)
  • Financial due diligence (quality of earnings, working capital, debt-like items)
  • Commercial due diligence (customers, suppliers, pricing power, churn, market position)
  • Optional: IT/cyber, HR, environmental, IP, real estate DD (deal-dependent)

3) Legal Due Diligence Checklist (Turkey)

A) Corporate and Governance

  • Trade Registry records, Articles of Association
  • shareholding structure and share transfers history
  • board/manager appointments and signing authority
  • shareholder resolutions and corporate books discipline
  • related-party transactions and approvals

Red flag: company operates with broad signing authority and weak minutes—this often hides unauthorized commitments.

B) Share Title and Encumbrances

  • whether shares are pledged
  • whether there are restrictions on transfer
  • whether any third-party rights exist (ROFR, options, etc.)

Red flag: missing clarity on share pledge or undocumented side agreements.

C) Material Contracts

  • top customer and supplier contracts
  • leases, distribution, agency agreements
  • loan agreements, guarantees, security documents
  • change-of-control clauses and consent requirements
  • default/termination triggers

Red flag: contracts signed by unauthorized persons or contracts that terminate on change of control.

D) Litigation, Disputes, and Enforcement

  • ongoing lawsuits and enforcement proceedings
  • threatened disputes and demand letters
  • administrative investigations and penalties
  • settlement history and recurring disputes

Red flag: repeated enforcement cases or “silent” disputes not recorded in official files.

E) Assets (Real Estate, Movables, IP)

  • title and encumbrance checks for real estate
  • equipment ownership, leasing vs ownership
  • pledges/mortgages, liens, attachments
  • IP registrations (trademarks, patents), software ownership
  • domain names, key licenses and sublicenses

Red flag: key IP owned by the founder personally, not the company.

F) Regulatory and Permits

  • operating licenses, sector approvals
  • compliance with industry regulations
  • data protection compliance where relevant
  • export/import compliance (if applicable)

Red flag: business depends on permits that are not transferable or are expired.


4) Tax Due Diligence Checklist (Turkey)

A Turkey-focused tax DD typically covers:

  • corporate income tax returns and reconciliations
  • VAT (KDV) returns and input/output logic
  • withholding tax filings and service/royalty classification risk
  • payroll/SGK cross-check and wage tax logic
  • related-party payments + transfer pricing risks
  • tax audits, assessments, disputes, and limitation timelines
  • invoice sampling and suspicious supplier/customer patterns
  • VAT refund positions and documentation strength

Red flag: large VAT receivables/refunds with weak documentation; repeated cross-border payments without strong contracts.


5) Financial Due Diligence Checklist (Quality of Earnings)

Key areas:

  • revenue recognition and customer concentration
  • gross margin stability and one-off items
  • EBITDA normalization (remove owner expenses, non-recurring gains)
  • working capital trends and seasonality
  • net debt and “debt-like items” (overdue taxes/SGK, unpaid bonuses, related-party balances)
  • capex needs and maintenance spending
  • cash conversion cycle (receivables collection reality)

Red flag: profits look strong, but cashflow is weak—often signals uncollectible receivables or hidden liabilities.


6) Commercial Due Diligence Checklist (What Actually Drives Value)

  • top customers: churn, renewal, pricing, dependency
  • supplier stability and alternative sourcing
  • sales pipeline quality and conversion rates
  • competitive landscape and market share signals
  • key employee dependency (single person risk)
  • product/service roadmap and differentiation

Red flag: revenue relies on 1–3 customers with contracts that can terminate easily.


7) Turkey-Specific Red Flags Buyers Should Watch For

Common Turkey patterns that create post-closing pain:

  • informal related-party payments (management fees, “expense reimbursements”)
  • off-book workforce signals (SGK and payroll mismatch risks)
  • broad signing authority and weak corporate approvals
  • missing or unreliable corporate books and minutes
  • unrecorded guarantees and security packages
  • tax/SGK arrears classified as “ordinary payables”
  • founder-owned IP and software code not assigned to the company
  • contracts that require consent for transfer/control change
  • “friendly” supplier invoices that don’t match real services (audit risk)

8) Turning Due Diligence Findings into Deal Protections

Due diligence findings should drive specific SPA terms:

A) Price Adjustments

  • net debt adjustments
  • working capital adjustments
  • specific deductions for quantified risks

B) Representations & Warranties + Disclosure Schedules

  • strict warranties on title, taxes, litigation
  • disclosure schedules to list exceptions
  • defined “proper disclosure” standard

C) Indemnities and Special Protections

  • specific indemnities for known risks
  • longer survival for tax/SGK
  • caps/baskets/de minimis aligned with risk profile

D) Escrow / Holdback

  • dedicated buckets (tax, litigation, general warranties)
  • release schedule and claim mechanism

E) Conditions Precedent (Before Closing)

  • corporate cleanup (minutes, authority updates)
  • settlement of related-party balances
  • obtaining key customer/landlord consents
  • release of pledges/mortgages (if required)

9) A Practical Due Diligence Process (Timeline Logic)

A practical DD process usually looks like:

  1. NDA + data room setup
  2. request list and document collection
  3. Q&A and management interviews
  4. red flag report (early)
  5. full DD report + risk quantification
  6. SPA drafting aligned with findings
  7. closing conditions and post-closing action list

Best practice: demand an early red-flag memo—don’t wait for the final report to act.


FAQ

How long does due diligence take in Turkey?

It depends on deal size and document readiness. Well-prepared targets move faster; messy SMEs take longer due to missing records and clarifications.

Can buyers skip due diligence if they trust the seller?

Not recommended. Trust is not a substitute for documentation—especially for tax/SGK and contract validity risk.

What’s the biggest DD mistake in Turkey?

Not quantifying risks and not converting findings into enforceable SPA protections (escrow, indemnities, conditions precedent.

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